3. Contribution of Each Accountable Entity ...................................................................................... 20 3.1 3.2 3.3 ANSP’s SHARE TO THE NATIONAL TARGETS .................................................................... 20 HANSA’s SHARE TO THE NATIONAL TARGETS.................................................................. 24 METSP’s SHARE TO THE NATIONAL TARGETS .................................................................. 25

Commission Regulation (EU) No 691/2010 of 29 July 2010 laying down a performance scheme for air navigation services and network functions and amending Regulation (EC) No 2096/2005 laying down common requirements for the provision of air navigation services.

•

Commission Decision No 2011/121/EU of 21 February 2011 setting the European Union-wide performance targets and alert thresholds for the provision of air navigation services for the years 2012 to 2014. Commission Regulation (EU) No 1191/2010 amending Commission Regulation1794/2006 of 6 December 2006 laying down a common charging scheme for air navigation services. Commission Regulation (EC) No 2096/2005 of 20 December 2005 laying down common requirements for the provision of air navigation services. Regulation (EC) No 549/2004 of the European Parliament and of the Council of 10 March 2004 laying down the framework for the creation of the single European sky (the framework Regulation) Regulation (EC) No 550/2004 of the European Parliament and of the Council of 10 March 2004 on the provision of air navigation services in the single European sky (the service provision Regulation) Regulation (EC) No 551/2004 of the European Parliament and of the Council of 10 March 2004 on the organization and use of the airspace in the single European sky (the airspace Regulation) Regulation (EC)No 1070/2009 of the European Parliament and of the Council of 21 October 2009 amending Regulations (EC)No 549/2004, (EC)No 550/2004, (EC)No 551/2004 and (EC)No 552/2004 in order to improve the performance and sustainability of the European aviation system. Commission Regulation (EU)No 255/2010 of 25 March 2010 laying down common rules on air traffic flow management Commission Regulation (EC) No 1315/2007 of 8 November 2007 on safety oversight in air traffic management and amending Regulation (EC) No 2096/2005 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No1592/2002 and Directive 2004/36/EC.

1.1 THE SITUATION
In order to meet the requirements of Commission Regulation (EU) no. 691/2010 of July 2010 (laying down a performance scheme for air navigation services and network functions and amending Regulation (EC) no. 2096/2005 laying down common requirements for the provision of air navigation services) Hellenic Air Navigation Supervisory Authority (HANSA) has prepared for Greece the present Performance Plan which covers the first Reference Period (RP1; 2012-2014). This Performance Plan has been developed at a national level and registers Greece’s intention, for the duration of the first reference period, to achieve the objectives of the Single European Sky and the balance between the needs of all airspace users and supply of services provided by air navigation service providers. • Accountable Entities:

The accountable entities covered by the present performance plan are the following: • HCAA/ANSP: The Greek Air Navigation Service Provider (ANSP) was certified by HANSA for a bundle of services (ATS, CNS, AIS) on 25 June 2010.The duration of the certificate is one (1) year. An extension of the certificate has been issued by HANSA until 30 April 2012. HANSA: A single NSA, the "Hellenic Air Navigation National Supervisory Authority" (HANSA), has been established functionally separated from the air navigation service provision. Law 3446/2006 establishes the NSA while Presidential Decree 150/2007 covers the organization, the staffing and the responsibilities of the NSA. Presidential Decree 103/2010 regulates the internal functioning of the NSA. METSP: The meteorological service for civil aviation is provided by the “National Meteorological Service”, the “Regional Met Centre MAKEDONIA” and the “Regional Met Centre ATA”, which are subordinated to the Ministry of Defence. HANSA certified the Hellenic National Meteorological Service Provider on 20 May 2010.The duration of the certificate is three (3) years. Geographical Scope:

•

•

•

The airspace under Hellenic responsibility is encompassed by the ATHINAI FIR/ HELLAS UIR as per AIP Greece. Two ACCs, the Athinai and Makedonia ACCs provide within the ATHINAI FIR/HELLAS UIR with air traffic services. The environment can be considered as highly complex due to the large number (10) of adjacent FIRs and the traffic profile (a lot of climbing/descending flights). Fifteen (15) TMAs are established at civil airports and eight (8) MTMAs at military aerodromes. The lower limit of TMAs is generally 1.000 ft. GND. The upper limit varies between FL 85 and FL 460. Twenty-six (26) Control Zones (CTRs) are established around civil airports and eight (8) Control Zones around military aerodromes.
1

The Athinai TMA is the only high complexity TMA. However, taking into account traffic complexity and distribution, the Makedonia, Kerkira, Iraklion and Rodos TMAs can also be considered as complex TMAs. There is no cross border provision of ATS. • Body providing aggregation of performance targets for FAB:

Greece is cooperating with other EU Member States (Cyprus, Malta and Italy) in establishing a Functional Airspace Block (FAB) which is called BLUE MED. However, the four States have decided that, since BLUE MED is not yet formed, each State should submit its own NPP.

1.2 OVERALL ASSUMPTIONS FOR RP1
For the development of the present Performance Plan, the following key factors have been taken into account:

•

General socio-economic situation of Greece:

In spring 2010 Greece jointed the three-year Economic Adjustment Programme and consequently adopted comprehensive fiscal consolidation measures.They are expected to have a dampening impact on domestic demand. However, successful and credible fiscal adjustment efforts are expected to compensate for the economic cost of adjustment and lead to the beginning of a recovery in the second half of 2011. Because of the general socio-economic situation though, it is difficult to draw exact conclusions as to how the economy will move in the long term. For the year 2011, fiscal tightening will have a strong contraction impact on economic activity, on the back of cuts in public wages, an increasing tax burden and ensuing declining disposable income and public spending. Real GDP is expected to further decline by 3% in 2011 – mainly due to carry-over effects – while growth is expected to turn around positively during the second half of the year, with the recovery gaining further momentum in 2012. Inflationary pressures have built up in the course of 2010, fuelled by the VAT-rates rises in March and July and the increase in excise duties on alcohol, tobacco and fuel. The contraction of economic activity, reflected in weakening labour demand from the retail, wholesale and construction sectors, is weighing heavily on employment which is set to fall by more than 5% over the forecast horizon. Reduced employment opportunities in the private sector, along with the recruitment freeze and cuts in short-term contracts in the public sector will push the unemployment rate up to just below 15% in 2012. Negative employment growth and declining wages should weigh on disposable income over the medium-term, dampening real demand.1

According to the Eurocontrol short – and medium term forecast of Service Units of May 20114, the traffic in Greece is going to increase at around 21% from 2010 to 2016. Below is a table with the total units for Greece between 2010 and 2016, according to EUROCONTROL forecasts, with the high, low and baseline scenario for each year:

Details on the calculations of the unit rate are given in chapter no. 2 “National performance targets and alert thresholds”. Overall status of Aviation Safety:

•

There are arrangements on safety both at State level and at ANSPs level. At State level the existing arrangements on safety are: • the National legal safety regulatory framework and • a series of safety relevant activities. Greece, in order to discharge its obligation to ICAO for the development of a State Safety Programme (SSP), has designated the Governor of Hellenic Civil Aviation Authority as the National Coordinator for the development of the Greek State Safety Programme (SSP). To this end, the HCAA Governor has established a relevant Committee. The primary task of this Committee is to collect and integrate all existing national arrangements and safety elements, aiming at developing an SSP manual as the basis for the establishment of the Greek SSP. The Committee, so far, has developed a considerable amount of material in coordination with all the relevant State aviation stakeholders. The establishment of national Acceptable Levels of Safety (ALoS) is still pending. The development of a list of national safety indicators and targets, such as the measurement of safety maturity, the extent of RAT use, the safety culture measurement (as required by the EC regulation 691/2010), has not been finalized yet. The completion of this task will allow the State to monitor the level of aviation safety.

5

•

Institutional context for ANS provision: o Ministry of Infrastructure, Transport and Networks: it is the Ministry responsible for the civil aviation in Greece HANSA: The Hellenic Air Navigation Supervisory Authority is the Greek NSA responsible for the certification, supervision and oversight of the Air Navigation Services Providers, according to the regulations of the European Commission for Air Navigation Services in the framework of the Single European Sky, including the Eurocontrol Safety Regulatory Requirements (ESSAR’s). ANSP: is the certified Air Navigation Service Provider responsible for ANS provision. The duration of its certificate has been extended by HANSA until 30 April 2012. Law 3913/2011 regarding the reconstruction of HCAA has been put into effect but its implementation will not affect the status of civil aviation safety. METSP: is the certified Meteorological Air Navigation Service Provider responsible for the provision of meteorological data. Military Component(HAF): The Military Authorities (Hellenic Air Force – HAF provide Air Traffic Services to civil aircraft at military Aerodromes/Terminal Control Areas. HAF is also user of some designated/reserved parts of the airspace. Civil military co-ordination is ensured through agreed procedures (use of LoAs etc).

o

o

o

o

1.3 STAKEHOLDER CONSULTATION
In accordance with the Performance Scheme Regulation, recital number 11, article 10 clauses 2 (b) and 3 (j), the following stakeholders’ consultation took place: 1. On 28/3/2011 between HANSA, ANSP and METSP experts for the costefficiency. 2. On 1/4/2011 between HANSA and ANSP representatives where guidance material for the preparation of the Performance Plan and the role of each accountable entity was presented. 3. On 19/4/2011 between HANSA and ANSP for the elaboration of the data that will be inserted in the Performance Plan. 4. On 7/6/2011 consultation with all relevant stakeholders (ANSP, METSP, IATA).All relevant information regarding the meeting is provided in ANNEX B “Stakeholders Consultation Material”.

6

2. National Performance Targets and Alert Thresholds

The following table lists all the Key Performance Indicators (KPI’s) for each Key Performance Area (KPA) and their status as mandatory or optional for the RP1 according to Commission Regulation (EU) No 691/2010:
KPA Local KPI for Target Setting in RP1 Effectiveness of safety management (Maturity) Application of severity classification scheme Targets for: *Separation infringements *Runway incursions *ATM special technical events Application of just culture Average horizontal en-route flight efficiency Minutes of en-route ATMF delay per flight Targets for: *ATFM airport delays *Additional time in taxi-out phase *Additional time in arrival sequencing/merging area Determined unit rate for en-route ANS Status Optional Optional Optional Optional Optional Mandatory Optional Mandatory

Safety

Environment

Capacity

Cost Efficiency

Table 2: KPI's for local target setting in PR1

2.1

PERFORMANCE TARGETS AND ALERT THRESHOLDS FOR RP1

This section presents, for each KPA, the KPI’s and associated targets that form Greece’s Performance Plan. It also presents the defined alert thresholds beyond which the alert mechanism may be activated. A summary of the National Targets and Thresholds is presented in the following table:
National Targets KPA (a) Safety KPI 2012 Not set for the first reference period En-route ATFM delay (minutes per flight) Not set for the first reference period Determined en-route unit rate (2011 prices in EURO) - Deviation over a calendar year by at least 10% of the actual costs versus the reference costs - Deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts 2013 2014 National Alert Thresholds

(b) Capacity

1.20

1.35

1.50

(c) Environment

(d) Cost-efficiency

35.36

33.95

32.81

Table 3: Presentation of the National targets and thresholds for RP1

7

A) SAFETY TARGET AND THRESHOLD For the first reference period the SAFETY key performance indicators, according to the Performance Scheme Regulation, are: (a) The first national safety KPI shall be the effectiveness of safety management as measured by a methodology based on the ATM Safety Maturity Survey Framework. This indicator shall be developed jointly by the Commission, the Member States, EASA and Eurocontrol and adopted by the Commission prior to the first reference period. During this first reference period, national supervisory authorities will monitor and publish these key performance indicators, and Member States may set corresponding targets. (b) The second national safety KPI shall be the application of the severity classification of the Risk Analysis Tool to allow harmonized reporting of severity assessment of Separation Minima Infringement, Runway Incursions and ATM Specific Technical Events at all Air Traffic Control Centers and airports with more than 150 000 commercial air transport movements per year within the scope of this Regulation (yes/no value). The severity classification shall be developed jointly by the Commission, the Member States, EASA and Eurocontrol and adopted by the Commission prior to the first reference period. During this first reference period, national supervisory authorities will monitor and publish these key performance indicators, and Member States may set corresponding targets. (c) The third national safety KPI shall be the reporting of just culture. This measure shall be developed jointly by the Commission, the Member States, EASA and Eurocontrol and adopted by the Commission prior to the first reference period. During this first reference period, national supervisory authorities will monitor and publish this measure, and Member States may set corresponding targets.EN 3.8.2010 Official Journal of the European Union L 201/13 Greece, for the first reference period, will not set any safety targets at National level. B) CAPACITY TARGET AND THRESHOLD For the first reference period, the mandatory capacity KPI is the minutes of en route ATFM delay per flight. It is defined as follows: (a) the indicator is defined as the difference between the take-off time requested by the aircraft operator in the last submitted flight plan and the calculated take-off time allocated by the central unit of ATFM” . (b) the indicator is given for each year of the reference period. In order to prepare the development of a second national capacity KPI, Member States shall report as from the first reference period: (a) the total of ATFM delays attributable to terminal and airport air navigation services; (b) the additional time in the taxi out phase; (c) for airports with more that 100 000 commercial movements per year the additional time for ASMA (Arrival Sequencing and Metering Area). The alert threshold for the first reference period, where an alert mechanism will be activated, is the deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts.

8

For Greece the capacity targets that would be consistent with the EU-target, as calculated by EUROCONTROL, are set as shown in the following table:
Capacity KPI ACC ACC Code 2012 F Intermediate Value Minutes of en-route 5 ATFM delay per flight ATHENS MAKEDONIA ANSP
Table 4: Reference values for capacity

2013 F Intermediate Value 0.24 0.26 0.32

2014 T

LGGGCTA LGMDCTA

0.29 0.28 0.37

0.20 0.21 0.26

Nevertheless, the minutes of en-route ATFM delay for the years 2012 to 2014 are expected to be higher than the reference values and reach the numbers shown in the table below:
Capacity KPI ANSP 2012 F Intermediate Value Minutes of en-route ATFM delay per flight ANSP 1.20 2013 F Intermediate Value 1.35 1.50
- Deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts

2014 T

Alert Threshold

Table 5: Presentation of en-route capacity target for RP1

The reasons for the discrepancy between the EUROCONTROL reference values and the targets set for Greece for the first reference period of the Performance Plan are being analytically explained in the paragraph “2.2 Consistency with the European Union-Wide performance targets – (b) capacity”. C) ENVIRONMENT TARGET AND THRESHOLD The EU-wide environment target is the average horizontal en-route flight efficiency. For the first reference period, Greece does not propose to adopt any environment KPI at National level.

D) COST-EFFICIENCY TARGET AND THRESHOLD For the first reference period, the mandatory cost-efficiency KPI is the determined unit rate for en route air navigation services, defined as follows: (a) the indicator is the result of the ratio between the determined costs and the forecast traffic contained in the performance plans in accordance with Article 10(3)(a) and (b) of the performance regulation; (b) the indicator is expressed in national currency and in real terms; (c) the indicator is provided for each year of the reference period.

5

Capacity reference values- EU Target ACC Breakdown

9

In addition, States have to report their terminal air navigation services costs and unit rates in accordance with Regulation (EC) No 1794/2006 and must justify to the Commission any deviation from the forecasts. The alert threshold for the first reference period, where an alert mechanism will be activated, is the deviation over a calendar year by at least 10% of the actual costs versus the reference costs. For Greece, the cost-efficiency targets for RP1 are the ones shown in the table below:
Cost KPI efficiency 2012 F Intermediate Value Real en-route determined unit rate (in EURO at 2011 prices) 2013 F Intermediate Value
- Deviation over a calendar year by at least 10% of the actual costs versus the reference costs

2014 T

Alert Threshold

35.36

33.95

32.81

Table 6: Presentation of en-route cost-efficiency target for RP1

2.2

CONSISTENCY WITH THE EUROPEAN UNION-WIDE PERFORMANCE TARGETS

This section sets out the justifications for Greece’s targets and their consistency with the EU-wide targets, in particular with due regard to the assessment criteria set out at Annex III of the Performance Scheme IR. For the performance reference period starting on 1 January 2012 and ending on 31 December 2014, the European Union-wide performance targets, according to Commission Decision No 2011/121/EU of 21 February 2011, shall be as follows: (a) environment target: an improvement by 0,75 of a percentage point of the average horizontal en route flight efficiency indicator in 2014 as compared to the situation in 2009; (b) capacity target: an improvement of the average en route Air Traffic Flow Management (ATFM) delay so as to reach a maximum of 0,5 minute per flight in 2014; (c) (c) cost-efficiency target: a reduction of the average European Union-wide determined unit rate for en route air navigation services from 59,97 EUR in 2011 to 53,92 EUR in 2014 (expressed in real terms, EUR 2009), with intermediate annual values of 57,88 EUR in 2012 and 55,87 EUR in 2013. For all key performance indicators applicable to the performance reference period, the alert threshold beyond which the alert mechanism referred to in Article 18 of Regulation (EU) No 691/2010 may be activated shall be a deviation over a calendar year by at least 10 % of the actual traffic recorded by the Performance Review Body versus the traffic forecasts expressed in en route service units: 108 776 000 in 2012, 111 605 000 in 2013 and 114 610 000 in 2014. For the cost-efficiency indicator, the costs evolution alert threshold beyond which the alert mechanism referred to in Article 18 of Regulation (EU) No 691/2010 may be activated shall be a deviation over a calendar year by at least 10 % of the actual costs at European Union10

wide level recorded by the Performance Review Body versus the reference determined costs level (expressed in real terms, EUR 2009): 6 296 000 000 in 2012, 6 234 000 000 in 2013 and 6 179 000 000 in 2014. The above are presented in the following table:
KPA KPI EU-WIDE TARGETS 2012 (b) Capacity Minutes of en-route ATFM delay per flight 0.7 2013 0.6 2014 0.5 - Deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts - Deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts - Deviation over a calendar year by at least 10% of the actual traffic versus the traffic forecasts - Deviation over a calendar year by at least 10% of the actual costs at EU-wide level versus the reference costs References for the activation of the thresholds EU-WIDE THRESHOLDS

The national capacity targets the first reference period were calculated on the basis of the en-route ATFM delay recorded during the three previous years, i.e. 2009-2011. The reasoning behind these figures is listed below: • The significant increase of overflights that has been documented as of 2003 onwards, mainly attributed to the continuous efforts for improvement of the route network has resulted to an increase in en-route ATFM delays. The economic situation in Greece has resulted in a big decrease in domestic flights that is expected to continue until the end of the year 2014. The STATFOR forecast data on traffic evolution for Greece for the first reference period show a sizeable increase of traffic at about 3% per annum. Having regard to the decrease in domestic flights and the evolution of overflights so far, Greece expects an increase in traffic higher than 3% p.a.. The economic situation, Greece being under the Economic Support Mechanism, and the austerity measures taken, in conjunction with the fact that the ANSP staff is part of the public sector, cannot guarantee immediate actions in personnel recruitment. Consequently, the existing personnel, which is additionally expected to decrease due to scheduled retirements, cannot easily cope with significant traffic increase. Furthermore, there is no evidence so far that adequate investments for infrastructure have been undertaken that could lead to capacity increase.

• • • •

•

6

If the Libyan situation still exists during the summer of 2011, the mean en-route ATFM delay will be deteriorated.

12

Cost-efficiency

Historically, the Greek en-route unit rate is well below the European average and is among the lowest in the European Union. For the first reference period, the cost-efficiency target of Greece is expected to present an annual reduction in the determined en-route unit rate of 4.3%. The Greek target therefore is consistent and even surpasses the EU-wide target. The following tables summarise all relevant costs. Full reporting tables are included as ANNEX A to this document.

1)

En-route SU Forecast (in thousands)

The Service Units forecasts used are from the STATFOR May 2011 forecasts:

2009 A En-route total service units prior to RP1 Forecast total service units used for the determined unit rate Source: % n/n-1 STATFOR service units forecast 7 (Baseline scenario) Date of STATFOR SU forecast: 4.139
MAY 2011

2010 A 4.454

2011 F 4.507

2012 F

2013 F

2014 F

4.139

4.698 STATFOR 7.6% 4.454
MAY 2011

4.860 STATFOR 3.4% 4.860
MAY 2011

5.041 STATFOR 3.7% 5.041
MAY 2011

STATFOR 4.2% 4.698
MAY 2011

1.2% 4.507
MAY 2011

% n/n-1 7.6% 1.2% 4.2% 3.4% 3.7% Table 9: En-route service units forecast used for the calculation of the national en-route costefficiency target

2)

Determined en-route ANS costs in nominal terms

The tables below show the efforts made to maintain costs at a stable level. It has to be stressed that, since 2010, Greek government has adopted austerity measures which have resulted in cuts in wages and increase in operating costs (mainly due to rises in VAT, fuel prices, electricity, telecommunications, water et.c.). This procedure is still ongoing and it is expected to affect the cost base at least for the year 2012, given the fact that all accountable entities in this Performance Plan are part of the Public Sector.

7

EUROCONTROL Short- and Medium-Term Forecast of Service Units: May 2011 Update

The following table provides the calculations of the conversion of the determined en-route costs from nominal terms into real 2009 terms. The projected inflation rates used were derived as described in section 1.2.

Independencies between targets The Key performance Areas covered by this Performance Plan, i.e. capacity and cost-efficiency, should not be considered as stand alone, performance in one area will affect performance in other areas. A balance should be found between the cost of investments necessary to provide adequate capacity and the cost of delays if insufficient capacity is provided. The cost-efficiency target adopted by Greece is consistent, and even surpasses, the EU-wide targets. On the other hand, the en-route ATFM delays are well above the reference values provided by Eurocontrol and as a result the capacity target is not consistent with the EU-wide targets. This is caused mainly because traffic has increased dramatically over the years, it is expected to continue to do so, but no new staff recruitments nor any investments for the improvement of the capacity target are foreseen due to the fact that Greece in under the European Support Mechanism. Nevertheless, HCAA has made an effort to expedite approval for the initiation of five major projects within the next 3 years, which would improve capacity and cost-efficiency but as these would take some time to implement it would be crucial to invest in the human factor.

16

2.3

CARRY-OVERS FROM THE YEARS BEFORE RP1

The following table provides an overview of the carry-overs form the years before RP1 that are relevant to the period covered by RP1.
2007 A 2008 A 2009 A 2010 F 2011 F 2012 P 2013 P 2014 P

(1) Adjustment total service units -5.702 10.138 1.634 Table 15: Carry-overs from the years before RP1- under(-) and over(+) recoveries (in nominal terms in EURO)

2.4
•

PARAMETERS FOR RISK SHARING AND INCENTIVES
Incentives:

For the time being, no incentive mechanisms are foreseen to be applied regarding the capacity and cost-efficiency targets.

• Risk-sharing: The traffic risk-sharing mechanism comprises the following: o Where, over a given year n, the actual number of service units does not exceed or fall below the forecast established at the beginning of the reference period by more than 2 %, the additional revenue or loss in revenue of the air navigation service provider with regard to determined costs shall not be carried over. o Where, over a given year n, the actual number of service units exceeds the forecast established at the beginning of the reference period by more than 2 %, a minimum of 70 % of the additional revenue obtained by the air navigation service provider(s) concerned in excess of 2 % of the difference between the actual service units and the forecast with regard to

17

determined costs shall be returned to airspace users no later than in year n+2. o Where, over a given year n, the actual number of service units falls below the forecast established at the beginning of the reference period by more than 2 %, a maximum of 70 % of the loss in revenue incurred by the air navigation service provider(s) concerned in excess of 2 % of the difference between the actual service units and the forecast with regard to determined costs shall be borne by the airspace users in principle no later than in year n+2. However, Greece may decide to spread the carry -over of such loss in revenue over several years with a view to preserving the stability of the unit rate. The following costs shall not be submitted to traffic risk sharing and shall be recovered irrespective of traffic evolution: (a) the determined costs established in application of Article 5(2) of EC Regulation 1191/2010 with the exception of agreements relating to cross border air traffic service provision; (b) the determined costs of METSP; (c) the carry-overs authorised from a previous year or reference period and bonuses or penalties resulting from incentive schemes; (d) the over- or under-recoveries resulting from traffic variations, which shall be recovered no later than in year n+2. Where, over a given year n, the actual service units are lower than 90 % of the forecast established at the beginning of the reference period, the full amount of the loss in revenue incurred by the air navigation service provider(s) concerned in excess of the 10 % of the difference between the actual service units and the forecast in respect of determined costs shall be borne by the airspace users in principle no later than in year n+2. However, Greece may decide to spread the carry-over of such loss in revenue over several years with the view to preserving the stability of unit rate. Where, over a given year n, the actual service units exceed 110% of the forecast established at the beginning of the reference period, the full amount of the additional revenue obtained by the air navigation service provider(s) concerned in excess of the 10% of the difference between the actual service units and the forecast in respect of determined costs shall be returned to airspace users in year n+2. The cost risk-sharing mechanism provides that: (a)where, over the whole reference period, actual costs fall below the determined costs established at the beginning of the reference period, the resulting difference shall be retained by the air navigation service provider, Member State or qualified entity concerned; (b)where, over the whole reference period, actual costs exceed the determined costs established at the beginning of the reference period, the resulting difference shall be borne by the air navigation service provider, Member State or qualified entity concerned without prejudice to the activation of an alert mechanism in accordance with Article 18 of Regulation (EU) No 691/2010; Points (a) and (b) may not apply to the difference between actual and determined costs which may be deemed to be out of the control of the air navigation service providers, Member States and qualified entities as a result of:
18

(i) unforeseen changes in national pension regulations and pension accounting regulations; (ii) unforeseen changes in to national taxation law; (iii) unforeseen and new cost items not covered in the national performance plan but required by law; (iv) unforeseen changes in costs or revenues stemming from international agreements; (v) significant changes in interest rates on loans. Where, over the whole reference period, actual costs are lower than the determined costs established at the beginning of the reference period, the resulting difference shall be returned to airspace users through a carry-over to the following reference period. Where, over the whole reference period, actual costs exceed the determined costs established at the beginning of the reference period, the resulting difference shall be passed on to airspace users through a carry-over to the following period. The national supervisory authority concerned shall explicitly agree to the carry-over after having ascertained that: (i) the variation of actual costs against determined costs is actually the result of developments that are beyond the influence of the air navigation service provider, Member State or qualified entity concerned; (ii) the variation in costs to be passed on to users is specifically identified and categorised.

19

3. Contribution of Each Accountable Entity

3.1

ANSP’s SHARE TO THE NATIONAL TARGETS

(a)Safety The SES regulatory framework requires that each certified ANSP has a Safety Management System (SMS) in place. The required Acceptable Levels of Safety (ALoS), to be agreed between HCAA and HANSA, are currently being developed.

Return on equity: For the calculation of the return on equity, the 10-year Greek Government Bond was used which was 10.17%

22

Investments: The list for the main CAPEX projects between 2012 and 2014, deemed crucial for the improvement of capacity and cost-efficiency, is shown in the table below. The present economic situation in Greece though, cannot guarantee that these investments will be implemented in due time.
Name Planned start date COM COM 2011 2011 Planned end date 2014 2014 Budget k€ 8.500 2.400

The FUA Concept in Greece, is based on the Protocol of Cooperation between Ministry of Defence and Ministry of Infrastructure, Transport and Networks. The implementation of the FUA Concept in Greece took place on January 2007 when the first AUP was published. The FUA Concept is based on three Levels: a) Strategic ASM - Level 1, b) Pre-Tactical ASM - Level 2, and c) Tactical ASM - Level 3. The three ASM Levels correspond with civil/military co-ordination tasks. Each Level is related directly to, and impacts on, the others. Strategic ASM at Level 1 consists of a joint civil and military process within a high-level civil/military National body, which formulates the National ASM policy and carries out the necessary strategic planning work, taking into account National and international airspace users requirements. 2. Pre-Tactical ASM at Level 2 consists of the day-to-day management and temporary allocation of airspace through the AMC. AMC is a joint civil/military ASM focal-point which has the authority to define ASM structures. Collects and analyses all airspace requests and decides the daily airspace allocation. Every day, the AMC promulgate the Airspace Use Plan (AUP) and amends, if needed, the Updated Use Plan (UUP) to the CFMU –CADF. A hard copy of AUP or UUP is distributed to the appropriate sectors of ATH/MAK/ACC . 3. Tactical ASM Level 3 consists of the real-time activation, or real-time reallocation of the airspace allocated at Level 2 and the resolution of specific airspace problems between civil and military ATS units : ATH/MAK/ACC and responsible Military units. Conditional Routes (CDRs) are established by the Level 1, allocated at Level 2 and utilised in a flexible manner at Level 3. CDRs are “non-permanent” parts of the published ATS route network. CDRs are established to offer more direct and alternative routes, through areas of Military TMAs and areas of temporary reservation for military activities. The performance of the FUA application is in conformity with: • COMMISSION REGULATION (EC) No 2150/2005, • EUROCONTROL Specification for the application of FUA. • EUROCONTROL Handbook for Airspace Management. According to our statistical data, the daily use of CDRs corresponds at about 4% of the total traffic (1500 flights per day) in average during working days. This percentage is increased to about 6% of the total traffic during weekends and national holidays.
26

1.

It is estimated that every CDR is used by 20 flights per day, in average. In total, for the 9 CDRs available, it is estimated that there are about 180 flights per day, using the CDRs, in average. This results in a saving of about 10NM per CDR, per flight, in total 1800NM per day.

4.2

ADDITIONAL KPI’s

There are no KPI’s set regarding FUA application for the first reference period.

27

5. Analysis of Sensitivity

5.1
•

EXTERNAL ASSUMPTIONS
Since 2010, Greek government has adopted austerity measures which have resulted in cuts in wages and increase in operating costs (mainly due to rises in VAT, fuel prices, electricity, telecommunications, water et.c.). This procedure is still on-going and it is expected to affect the cost base at least for the year 2012, given the fact that all accountable entities in this Performance Plan are part of the Public Sector. As a result, it is not feasible to make any credible assumptions as to how these measures will affect total costs. Given the present situation regarding the en-route ATFM delays, if traffic growth is going to be substantially bigger than the one forecasted, the capacity target is expected to deteriorate.

•

5.2

COMPARISON WITH PREVIOUS PLANS

There are no previous Performance Plans for comparison.

29

6. Implementation of the Performance Plan

•

HANSA will monitor the performance of the accountable entities against the targets set out in the present Performance Plan, starting six months after the commencement of RP1, i.e. July 2012, and every six months from then on. This monitoring will not necessarily be accompanied by any formal reporting. HANSA will also periodically analyse the KPIs to assess progress against targets and any reduction in performance that is identified will be discussed with the appropriate stakeholders with a view to agreeing on the necessary corrective action to be taken. For the purposes of formal reporting, as required by the Performance Scheme Regulation, the proposed schedule is as follows, in the year following the end of each of the years 2012, 2013 and 2014: 1. April 2013, 2014, 2015 The accountable entities report the actual performance of the previous year and the revised plan for the remaining years of the reporting period. Any deviations between the forecasted figures in this performance plan and the actual figures should be explained. Costs that are deemed uncontrollable by the accountable entities must be set out clearly so they can be excluded from the cost-risk sharing. 2. May 2013, 2014, 2015 HANSA reviews the submissions by the Accountable Entities and seeks explanations and clarifications from them of any deviations. HANSA evaluates any requests for carry-overs of changes deemed uncontrollable, according to the article 11a, paragraph 8c, of the Charging Scheme Regulation. HANSA will decide whether the alert mechanism should be invoked, according to article 18 paragraph 2 of the Performance Scheme Regulation. After the review, HANSA prepares the Annual Progress Report and submits it to the State for adoption. 3. June 2013, 2014, 2015 State reviews the Annual Progress Report and HANSA makes any amendments deemed necessary. The State approves the Annual Progress Report and submits it to the Performance Review Body for approval.

FOR THE NATIONAL PERFORMANCE PLAN OF GREECE REFERENCE PERIOD 1 2012-2014

HCAA HQ, 7 JUNE 2011

53

•

The Acting Director of the Hellenic Air Navigation Supervisory Authority (HANSA), Mr. Michael Panagiotopoulos, opened the Stakeholders’ Consultation meeting at 9:30 a.m. on 7 June 2011 and welcomed the attendees (see list as ANNEX).He commented on the fact that this was the first time such a meeting took place, its importance for every stakeholder concerned and hoped for a fruitful outcome of the meeting. The Deputy Governor of HCAA, Mr. Gregory Nanidis, also welcomed those attending and expressed, as former Director of HANSA, the view that the work done on the Performance Plan was at a very good level and invited the Airlines’ representatives to feel free to contact him for any issue that might arise. Mrs. Kallirroy Anastasopoulou, on behalf of HANSA, made a brief introduction to the Greek Performance Plan and presented a set of slides regarding the key features of the Performance Plan and the targets set at national level for both the Capacity and Cost-efficiency performance areas.
The Assistant Director of IATA, Mr. Laurie O’Toole, thanked everybody and praised Greece for the excellent work done on the Performance Plan which was precise and to the point. He also made a reference to the difficulties regarding the economic situation of Greece. He enquired if the decrease in the unit rate, which he found very good and welcomed, would not subsequently be affected by uncontrollable costs. He also stressed out that the forecasts for the capacity target were too high and not acceptable by IATA as the delays mean extra revenue loss for the users.

•

•

•

•

Mrs. Theodora Syrma of HANSA, responded that the biggest impact on the unit rate was expected to come from wage cuts and limitations in investments. Mrs. Niki Gargareta from the HCAA/ANSP/Economics and Supply Division stated that the costs presented reflected the present situation and there was no possibility to make any other forecasts. Mrs. Dimitra Taniskidou the FMP Manager from HCAA/ANSP, commented that the figures for the ATFM delays were based on the fact that traffic has increased dramatically but no new staff recruitments nor any investments for the improvement of the capacity target were foreseen. As a result, these figures could deteriorate. HANSA explained that there is a strong inverse correlation between the unit rate and the delays. On behalf of IATA it was said that the rising figure of ATFM delays would raise serious concerns from the side of the PRB and commented on the decreasing number of staff. It was also noted that no investment plan was included in the Performance Plan.
54

•

•

•

•

•

Mr. Panagiotopoulos and Mr. Malikoutis from HANSA agreed that the continuous decrease in staff was a major issue and asked IATA for support on this subject. They also pointed out that under the present economic conditions there was no plan (at that moment) for new staff recruitment. Mr. Spyros Gavanozis from the HCAA/ANSP/Electronics Division agreed with HANSA and also requested the support of IATA and IACA for new staff and investments.
Mr. Jacques Pech from Air France congratulated HCAA for the good results on cost efficiency, but thought there should not be any trade-offs between cost efficiency and capacity : the increase of delays is not acceptable. There should be at least stabilization.

•

•

•

Mrs.Dimitra Taniskidou, the FMP Manager from HCAA/ANSP stressed that traffic continued to increase throughout the years while staff was decreasing mainly due to retirements. Existing ACC staff has done its best to manage the traffic but with no investments and no recruitments it would come as no surprise if even these high ATFM delays would rise instead of decrease. Support from the Government would be essential to improve the situation. IATA understood that the existing system would need renovation and asked for a proposal on behalf of HCAA. Mrs. Dimitra Taniskidou the FMP Manager from HCAA/ANSP said that adequate investments were essential for the provision of good services but as these would take some time to implement it would be crucial to invest in the human factor. Employees should be rewarded in order to perform better. IATA pointed out that the delays target was as critical as the costefficiency target also for EC and the PRB. Mr. Spyros Gavanozis from the HCAA/ANSP/Electronics Division said that a selection of five of the most crucial investments was made and this information was available through the LSSIP Greece but pressure should be put to the relevant Ministries so that these investments could be implemented. IATA advised that these five investments should be included in the Performance Plan with an explanation of the benefits they would provide in each target and their relevance with SESAR ATM Master Plan. Mrs. Constantina Andrikopoulou from the HCAA/ANSP Communications Division summarized the existing situation by pointing out that HCAA was part of the public sector and this should be taken into consideration because it meant reduction in salaries across the
55

•

•

•

•

•

•

board, no investments because of the economic situation in Greece and no possibility for new recruits. She also confirmed that HCAA has made an effort to expedite approval for the initiation of five major projects within the next 3 years, which would improve capacity and cost-efficiency. The relevant information has been included in the Performance Review Report. However, the procurement budget is frozen for the time being.
• IATA believes that the targets set at EU-wide level were relatively easy to achieve by all States, especially the cost-efficiency target in real terms in view the forecast traffic increase and allowance for inflation.

•

Mrs. Theodora Syrma from HANSA said that the targets were decided when there was a more favorable economic situation throughout Europe. Given the current financial difficulties these targets might not met by all the States and that would mean the activation of the alert mechanisms. Changes in the Performance Plans would also be probable. Mr. Angelos Malikoutis form HANSA pointed out that the human factor was the most important element, as well as technological investments & equipment for ATS.
IATA requested the following information:

•

•

o o o

How the cost of capital was calculated If the latest Service Units forecast was taken into consideration The relationship between the determined costs and possible changes Why investments were not included in the Performance Plan while they were provided in the LSSIP Greece.

o

•

Mrs. Niki Gargareta from the HCAA/ANSP/Economics and Supply Division answered that for the calculation of the cost of capital the government bond rate was taken into account which was around 10,17%. Mrs. Elpida Koryfidou from the HCAA/ANSP/ATS Division said that details on investments were not provided because it was not certain that they would be made but they were available and they would be inserted in the Performance Plan.
IATA commented that if FABs were implemented as originally envisaged it would be to the benefit of everyone concerned. While FABs were producing very welcome operational savings in delay and fuel terms, unfortunately they were not providing real savings that were expected of them. IATA was disappointed because lots of talking and meeting about FABs had taken place but without tangible real savings and efficiency results so far. In the second 56

•

•

reference period EC targets were likely to more ambitious and they would be met better if FABs were implemented.

•

Mrs. Constantina Andrikopoulou from the HCAA/ANSP/ Communications Division said that the geographical position of Greece should be considered as it is adjacent to countries not bound by EU regulations or even EUR Regional procedures and this particularity affects the efforts that need to be made in terms of personnel, procedures and systems to achieve interoperability. This has an impact on both capacity and cost-effectiveness. Regarding the terminal charges IATA wanted to know if Greece would subsidize them as it did the two previous years, a measure that was very welcomed from the users. Mrs. Theodora Syrma from HANSA responded that the same proposal for a 50% subsidy on the terminal charges for the year 2012 was made to the relevant Ministries and the answer was still pending but was expected around the end of July. This measure was considered very important given the crucial contribution of tourism in the economy of Greece.
IATA pointed out that a weakness of the Performance Plan of Greece was the lack of investments. The cost-efficiency target was welcomed but the ATFM delays were unacceptable taking into consideration the rising prices in fuel.

•

•

•

•

Mr. Michael Panagiotopoulos from HANSA said that that with a small rise in the unit rate the benefits on capacity would be multiple. Mrs. Dimitra Taniskidou the FMP Manager from HCAA/ANSP said that regarding the capacity target two elements should be considered, the staff reduction and the lack of investments.
IATA stated that, according to the Performance Scheme Regulation, EC and PRB would comment on the performance plan recommending what has to be done. IATA was reporting its views and requirments of all the NPPs to the EC/PRB.

•

•

•

Mrs. Theodora Syrma from HANSA noted that the measures undertaken by the Greek government under the agreement with the IMF and EU have an impact on delays and it’s up to the EU to either consider these delays acceptable under the current financial circumstances or propose and enable appropriate measures to alleviate the problem. IATA asked about the status of the privatization of the Airports and hoped that if this should happen there would not be imposition of fees as high as in AIA. Mr. Jacques Pech from Air France said that for Air France the routes towards Greece were increasing because of an increasing market, but
57

•

•

also due to the reasonable cost of navigation charges in Greece. But the increase from Air France and all other airlines should be helped by good performances in capacity from HCAA. Therefore he requests that the delays issue be dealt. • Mrs. Nicole Ammann from Swiss Air said that it was clear that increases in traffic should be dealt with by adequate investments. Mr. Laurie O’Toole from IATA thanked everybody for the good cooperation. Mr. Michael Panagiotopoulos from HANSA thanked the participants and closed the consultation meeting at 12:00 on 7 June 2011.